This privacy policy applies to the entire contents of the platform "Gimibits" operated by Xpesa Ltd. ["Xpesa"] which may be referred to hereon in as "we " or "us " or "our " (as applicable)] including, without limitation, website or any application or software used to access the platform ("Website" or "mobile application or app").

Please read the Privacy Policy below carefully before using Xpesa. By using or registering on Xpesa, you accept and agree to the terms of this Privacy Policy. If you do not accept these terms, you will not be allowed to access Xpesa.

The Users are responsible for keeping their information current. The User shall update their information by contacting us at [email protected] , and we will use reasonable efforts to process any change the User seeks to make; provided, however, that requests to delete information are subject to internal reporting, processing, retention policies and all applicable existing or potential legal obligations.

We at Xpesa are committed to preserving the privacy of all visitors to our platform [*]. We are committed to ensuring that all services and activities made available via the platform Xpesa will be provided in a safe and secure online environment.

Please read the following carefully to understand our views and practices regarding the User Information. The Privacy Policy can be found on our platform at https://Xpesa.io/privacypolicy.php

Introduction

  • Xpesa ("Xpesa, we, us") recognizes that people who use Xpesa's service ("you" or "User") value your privacy. This Privacy Policy details important information pertaining to the collection, use and disclosure of User information collected on Xpesa's website located at [*] www.Xpesa.io , the related mobile app, and any other features, tools, materials, or other services (including co-branded or affiliated services) offered from time to time by Xpesa or its affiliate companies (the "Service"). Xpesa provides this Privacy Policy to help you make an informed decision about whether to use or to continue using the Service.
  • This Privacy Policy should be read in conjunction with our Terms & Conditions. By accessing the Service, you are consenting to the collection and use of information practices described in this Privacy Policy.
  • The User's use of the Service and any information the User may provide through the Service remains subject to the terms of this Privacy Policy and our Terms & Conditions, as each may be updated from time to time.
  • Any questions, comments or complaints that you might have should be emailed to [*] or forwarded in writing to: [*], [email protected]

Information Collected from the Users

By choosing to use our Service and by submitting information to us through your use of our Service it shall be deemed that you have accepted the terms of this Privacy Policy, which shall apply to the User. You provide certain personal information to Xpesa when using or seeking to use the Service, such as registering for an account, details for verification,input(s) during trading on the exchange, financial details, contact information, posting messages, taking advantage of promotions, responding to surveys or subscribing to newsletters or other mailing lists.

  • The information may be collected from the User in a number of ways which may include collecting personal information if the User chooses to create an account with us, agreeing with the terms and conditions and accepting the privacy policy of Xpesa while using the Services. The User may also be required to complete an online survey or feedback form, sign up or email us to receive communications from us. We may also ask the User to provide information regarding his/her contact details including name, email address, mailing address, telephone number, age, gender, date of birth, credit card & billing information, profile picture, username, locations, responses to surveys, communications sent by you to us etc.
  • In addition to the above, we may need to verify your identity in order for you to use some aspects of the Service. For purposes of verification, we may also collect the following personal information from you:
    • Passport information;
    • Government-issued residence proof;
    • User's bank account details and proof of the same;
    • Tax-related information; and
    • other information as may be required to verify you in accordance with applicable laws and regulations.
  • We may require you to furnish information about the payment methods such as credit/debit cards, e-wallets and other online payment methods. We may also require you to furnish additional information, including but not limited to, billing address, card type, number, expiration date, card security code etc. If you choose to access any Service of Xpesa which requires payments, you may be required to furnish the above stated details.
  • When you use our mobile app, we also may collect mobile device information like operating system and hardware type, numbers or codes that are unique to your particular device, device information, default device language, the location of your device (at a GPS level), and app usage information. This data also may be linked to your other information, including your location data.
  • Cookies: When you visit the Site, we may send one or more cookies - small files - to your computer or other device, which may enable us or others to uniquely identify your browser. Xpesa uses both session cookies and persistent cookies. A persistent cookie remains after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the site. Persistent cookies can be removed by following your web browser help file directions. Session cookies are temporary and typically disappear after you close your browser. You may be able to reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of the Site or Service may not function properly if the ability to accept cookies is disabled.
  • Log File Information: When you use our Service, our servers may automatically record certain information that your device sends whenever you visit any website and use certain apps. These server logs may include information such as your web or app request, Internet Protocol ("IP ") address, browser type, browser language, referring/exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time of your request, and one or more cookies that may uniquely identify your browser.
  • Clear GIFs Information: When you use our Service, we may employ technology such as "clear GIFs " (a.k.a. Web Beacons) which are used to track the online usage patterns of our User(s). In addition, we may also use clear GIFs in HTML-based emails sent to our users to track which emails are opened by specific users.

Use of Information by Xpesa

  • We may use your personal information to operate and maintain the Service. The information may also be used to provide, to you, the features and functionality of the Service, including but not limited to the following:
    • providing you with our products, services etc.;
    • processing and responding to your enquiries or feedback;
    • personalizing your use of the Service,
    • alerting you to new features, special events, products and services, or certain third-party products or services in which we think you will be interested;
    • enforcing the legal terms and conditions that govern your use of the Service; and
    • contacting you about your account or profile.
  • We may use your information (both personal and non-personal information) to send you marketing and advertising content, including sending you advertising through multiple channels, such as direct mail, email, push notifications and display media. We may send you advertising or content pertaining to our products and services, or products and services that we market on behalf of another company or any other entity.
  • We may use your information to communicate with you about:
    • our products and services in which you may be interested provided that you have not requested otherwise;
    • newsletters and information for which you have signed up; and
    • non-marketing or administrative purposes (such as notifying you of major changes to the Service or for customer service purposes).

Sharing of Information

  • All User information collected by us through the Site shall be protected and not consciously shared with any third parties other than in the following circumstances:
    • Shared with Xpesa's affiliate and associated entities for marketing and advertising requirements in relation to our services;
    • Shared with those who provide to us or affiliate entities products or services that support the services that we provide;
    • anyone we transfer our business to in respect of which you are a customer or a potential customer;
    • If required by governmental, regulatory or law enforcement agencies; and
    • If required by law to be supplied to any entity.

Monitoring of Transactions & Customer Support

  • All account transactions are recorded on our computer system. We also carry out routine monitoring of all transactions as they take place, to assist us in improving the Service, we provide to you.
  • Telephone conversations of the User(s)with our Customer Support Centre, may be recorded, to assist us in training, quality management and to allow for the speedy resolution of the queries.
  • All communications with Xpesa and its Customer Support shall be conducted in parliamentary language (language which is not offensive and/or abusive). Xpesa prevents and prohibits any such use of offensive and/or abusive language and strictest of actions shall be taken against the User who uses such offensive and/or abusive language including but not limited to suspension and/or termination of the User Account and/or any other legal action.

User's Choices

  • Xpesa shall process your personal information in accordance with this Privacy Policy and shall provide you with choices as set out below:
    • You can access and update certain personal information Xpesa holds about you at any time by logging into your account via the Service. You can update your marketing preferences and whether you would like us, to send you newsletters. You can also unsubscribe to marketing emails and newsletters by using the 'unsubscribe' feature in the communication.
    • We may occasionally send visual media to you, whether through web or mobile browsers or mobile applications. You may unsubscribe to such visual media displays by emailing us at [email protected] You may opt out of tracking for mobile advertising through the settings on most smartphones, and you may learn more about these settings through those mobile device platforms, i.e., Google (here) and Apple (here). (Please note that these companies may change either the way these settings operate, the content or the availability of these pages.)
    • We may occasionally send you push notifications to your mobile device. You can turn off certain push notifications in the account settings of your Xpesa Account. You can also turn off push notifications specific to our Service in the settings on your mobile device.

Third Party Sharing, Advertising and Analytics

  • Certain advertisements appearing on our Service are delivered by our advertising partners. Our advertising partners may use cookies and other similar technologies, often in conjunction with unique (anonymous) cookie identifiers, to collect data about your activities and interests, including the technologies described above. Some of these partners may use mobile device identifiers, such as Apple IDFAs and Google/Android Advertising IDs. Doing this allows the ad companies to recognize your computer or device each time they send you an online or mobile advertisement. In this way, the advertisement companies may compile information about where you, or others who are using your computer or device, saw their advertisements and measure your interaction with each advertisement. This information allows advertisement companies to deliver targeted advertisements that may be of increased interest to you, both on our Service and elsewhere online. Just as these technologies may be used to target ads on our websites and apps, we, or our advertising partners, may use these same technologies and data points (e.g., mobile identifiers, cookie identifiers, location-based data), through our Service or through other services, to target advertising (for ourselves or other companies) on other sites or mobile apps. Sometimes, these identifiers may be derived from a hashed or encrypted version of personal information such as your email address. We may use this information to measure the performance of our advertising as well, for instance, to evaluate which ads or content our users prefer, or which are most effective. In addition, sometimes we or an advertising partner may tailor advertising to you across different devices.
  • Running the platform Xpesa may disclose the information it collects about the User to:
    • to its service providers, to its affiliates, sponsors, suppliers and others who help provide the platform to the User;
    • to licensors, activity and event partners and other third parties for their own marketing purposes, such as to provide information to the User about their new developments, special events, programs, services, activities, products, attractions, promotions and other important information;
    • third parties to provide analytics or to confirm/update information provided by the User;
    • third parties in the event of any reorganization, merger, sale, joint venture, assignment, transfer or disposition of all or any portion of the [*] business or other operations (including without limitation in connection with bankruptcy or any similar proceedings); and
    • or as otherwise authorized by the User.
  • We may also share the User's personal information in response to a legal order or official request; when we believe the User have acted in violation of the Terms & Conditions of Xpesa; to investigate, prevent or take action regarding suspected illegal activities, fraud or potential threats; to exercise legal rights or defend against claims; or as otherwise permitted or required by law.
  • We also may use, share or sell non-personally identifiable information with third parties. Additionally, we may take personally identifiable information and de-identify it and share it in a de-identified form with advertisers, business partners, and/or third parties in order to analyze usage of the services in order to improve our services and the User experience or for any similar purposes. It is to note that such data will not be re-identified and the contracting parties would be asked to agree to keep the data in its de-identified form after such use.
  • If the User elects to participate in any promotions, surveys, questionnaires, or other events during his/her visit to Xpesa, the rules or terms and conditions for those events may indicate that the User's information will be shared with third parties with his/her consent. The Users are advised to review the applicable rules and/or terms and conditions for any promotions, surveys, questionnaires or events.

Information Security

  • We are committed to protecting the security of your personal information. Protection of the User Information, including the registration details and any debit or credit card information the User provides to us, is a priority for us. We use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure.
  • Any personal information which identifies the User will be encrypted at all times whilst in transit over the internet. The technology used by us encrypts any information sent by the User on secured pages. Our server then reads the information using a private key. This means that your information, be it debit or credit card information or any other personal details, is turned into a code that can only be decoded with the private key or password.
  • Whilst neither we, nor any other organization, can guarantee the security of information processed online, we do have appropriate security measures in place to protect your personal information. For example, we store the personal information you provide on computer systems with limited access that are located in facilities to which access is limited.
  • To further protect your privacy and security, we reserve the right to take reasonable steps (such as requesting your password) to verify your identity before granting you profile access or making corrections.
  • Additionally, you should ensure your password is kept secret at all times. You will be responsible for maintaining the secrecy of your password and account information.

Unsubscribing to Communications

  • If the User does not want to receive any e-mails from us in the future, they are required to let us know by dropping an email to us. We will use our reasonable endeavours to remove the User's name from the related mailing list within fourteen (14) working days of his/her request. The User may also change his/her preferences at any time by revising his/her account profile by un-ticking the boxes for the previously opted communications.
  • The User may also click the "unsubscribe" link at the bottom of any emails he/she may receive from us and follow the necessary instructions provided.

Privacy Measures for Minors

  • Xpesa is intended for persons who are eighteen (18) years of age or above. If the User is under eighteen (18) years of age, he/she shall not be permitted to use the platform 'Xpesa'.
  • If the User is a parent and/or guardian and believe that we may have inadvertently collected personal information from their child, they can notify us immediately by sending an email to: [email protected]

Legal Compliance

  • Xpesa and its owners take a proactive approach to User privacy and ensure that all reasonable steps are taken to protect the privacy of its Users throughout their visiting experience.
  • Xpesa website and/or app complies with all relevant laws for User privacy, specifically this policy has been made pursuant to the provisions of the Information Technology

Changes and Updates for Information

  • This Privacy Policy may be revised periodically and this will be reflected by the "Last update posted " date above. Please revisit this page to stay aware of any changes. If there is a revision to this Privacy Policy, which is material, we will notify you by contacting you through the email address associated with your User account.
  • Contact Information: Please contact Xpesa with any questions or comments about this Privacy Policy by emailing us at [email protected]
  • The User is responsible for keeping his/her information current. The User may update his/her information by contacting us at [email protected] and we will use reasonable efforts to process any change the User makes; provided, however, that requests to delete information are subject to our internal reporting, processing and retention policies and all applicable legal obligations.

Language

All communications between the User and Xpesa, the Promoter, and/or any other entity shall be communicated in written form vide Electronic Mail (E-Mail) and in English language only. Further, all communications between the User and the Customer Support shall also be conducted in English language only.